South Australian Branch Australasian Radiation Protection Society (ARPS) Submission to Senate Inquiry: Selection process for a national radioactive waste management facility in South Australia (Submission No 66) __________________________________________________________________________________ The Australasian Radiation Protection Society is a professional society that promotes the principles and practice of radiation protection. It establishes and maintains professional standards amongst its members and advises on safe use of radiation for its many applications in industry, research and medicine.

Until now the Society has not had direct input to the National Radioactive Waste Management Project. It has viewed the public consultation process as one carried out between the Federal Department of Industry, Innovation and Science and the local communities who have put forward sites for consideration under the project.

This submission relates to points (b) and (e) of the Terms of Reference, ie in relation to the discussion around the definition of broad community support and the question as to whether the community views of the whole the Eyre Peninsula or the whole of South Australia should be taken into consideration.

While the Terms of Reference of the Inquiry are narrowly targeted to the site selection process it is important that this process is viewed in the light of two major aims of the Project:

For Australia to meet its responsibilities to manage its own radioactive wastes including those originating from South Australia;

To manage waste radioactive materials produced as a by-product of beneficial use of radiation in Australia: medical research, diagnosis and treatment of diseases, industrial processes and scientific research.

Our Society believes that it is appropriate that consultation occurs at the level of the local community. However, if it is decided from the deliberations of this Inquiry that public consultation will be extended to the wider South Australian community, the SA Branch of ARPS requests community views should be sought from:

1) South Australians who utilise radioisotopes in medicine, industry and research, particularly those who are responsible for management of waste radioactive materials

2) (where practicable) the many tens of thousands of South Australians from all parts of the community who have benefitted from diagnosis or treatment of life-threatening medical conditions using radioisotopes produced in Australia at the Lucas Heights facility.

These groups from the community are not organised into lobby groups of any form and therefore their views may be overlooked or undervalued in the consultation process.

Regarding point (1) above, many of our members advise on the safe management of radioactive materials. Over a period of decades legacy radioactive wastes used in industry, research and medicine have accumulated in South Australia (and Australia more broadly). The quantity of legacy radioactive materials is not substantial, and storage at multiple sites in South Australia is safe and compliant with current regulations.

However, radioactive materials are classified as hazardous materials and some represent a security concern. Hospitals and university campuses are not the place for storing unwanted hazardous materials. It is clearly more desirable to have a centralised managed facility which is purpose-built for the management of radioactive materials as there are for chemical or physically hazardous materials. After decades without progress, this National Project offers room for optimism that our waste material can be removed from the many individual sites across Australia and managed in accordance with international best practice.

On point (e) of the Terms of Reference, we comment that compared to any other small scale semiindustrial operation or a hazardous waste disposal or management process being proposed, the level of consultation with the local community is exceptional. The public consultation process in this case of radioactive waste materials may be contrasted with the process followed when asbestos or hazardous chemical waste disposal sites are established. Asbestos, for example, is a carcinogenic material with no half-life: once disposed of it persists in the environment forever. Radioactive materials will eventually decay away.

We note that the Inquiry website quotes the undertaking by the Government that it will not impose a facility on an unwilling community. We also note that the Government has indicated that no individual or group has an automatic right of veto.

Our concern is that in meeting demands from special interest groups who may not be from the local community and do not necessarily represent the local community, the requirements for demonstrating public acceptance will become unreasonable. Given the important service that this facility will provide to South Australia and Australia it is important that the project be given a reasonable opportunity to succeed. Should consideration of the current sites in South Australia fail, South Australians must then rely on other states or territories to accept the radioactive wastes from our hospitals and universities.

In summary, the Australasian Radiation Protection Society holds that the views which are the most important are those sought from the local community. The public consultation process should take into account the benefits enjoyed by all the South Australian and Australian community from past and future operations of the Lucas Heights reactor, and the use of radionuclides more broadly in science, medicine and industry. Any local community which accepts the establishment of a facility is providing a valuable service to the Australian community with minimal associated risk. Consultation should take place with a constructive intent, allowing the opportunity for fair input from the community while giving the facility every opportunity to succeed.

I Furness Chair, South Australian Branch Australasian Radiation Protection Society

FEDERALSubmissions about the proposed National Radioactive Waste Management Facility in Kimba or the Flinders Ranges. The Standing Committee on Environment and Energy are accepting submissions to the ‘Inquiry into the prerequisites for nuclear energy in Australia’ until 16 September 2019. Please write your own submission or use FOE’s online proforma.

Nuclear facilities, including power stations and radioactive waste dumps, are now banned in Queensland.

Nuclear facilities banned under the Act include:

·nuclear reactors (whether used to generate electricity or not);

·uranium conversion and enrichment plants;

·nuclear fuel fabrication plants;

·spent fuel processing plants; and

·facilities used to store or dispose of material associated with the nuclear fuel cycle e.g. radioactive waste material.

Exemptions under the legislation include facilities for the storage or disposal of waste material resulting from research or medical purposes, and the operation of a nuclear-powered vessel.

1 FEDERALSubmissions about the proposed National Radioactive Waste Management Facility in Kimba or the Flinders Ranges. The Standing Committee on Environment and Energy are accepting submissions to the ‘Inquiry into the prerequisites for nuclear energy in Australia’ until 16 September 2019. Please write your own submission or use FOE’s online proforma.

Australia has long rejected nuclear power, and it is banned in Federal and State laws. The nuclear lobby is out to first repeal those laws, and then to get the Australian government to commit to buying probably large numbers of Small Modular Nuclear Reactors (SMRs) . This could mean first importing plutonium and/or enriched uranium, as some reactor models, (thorium ones) require these to get the fission process started. That would, in effect, mean importing nuclear wastes.

There’s an all-too short period for people to send in Submissions to the 4 Parliamentary Inquiries now in progress.